Draft ISO 14001:2015 Standard Available for Public Comment

by Foley & Lardner LLP
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The revision of the ISO 14001 standard is now open for public comment, with the final standard publication expected in 2015, affecting over 280,000 certified organizations worldwide. Once final, the standard is expected to be in place until 2025.

Keeping the standard current with today’s environmental challenges, as well as positioning for future emerging trends, are core motivating factors in updating the standard. Environmental liability continues to expand beyond regulatory compliance to include operational, reputational and strategic business risk management. The new standard is shaping up to support environmental risk management as a core business objective and will therefore affect cross functional segments of the organization including environmental managers and business leaders.

A summary of key concepts incorporated into the draft standard include:

Organizational Context

By considering the context of the organization, the EMS scope will expand to include evaluation and understanding of both the external and internal context of the organization in relation to the environment. This means that organizations will not only consider the impact of their activities on the environment, but also the impact of the environment on their activities (e.g., including anticipated impacts from climate change, raw material scarcities, energy management, etc.).

The scope of the EMS will be expanded to include a life cycle review of the inputs (raw materials) and outputs (products) that the organization can control or influence, and their potential impact on the environment. This requires longer term risk forecasting as well as a broader value chain perspective, rather than just within the operational footprint of the organization.

In addition, organizations will also need to consider the needs and expectations of interested parties, including their supply chain and end users (i.e., stakeholder engagement).

The emphasis on supply chain and stakeholder engagement will provide expanded opportunities for reducing environmental impacts from the organization’s broader footprint.

Leadership

The new emphasis on leadership is intended to ensure that environmental management is embedded at the strategic level with a clearer link to management of the overall business. Top management must ensure that objectives and targets are consistent with the organization’s strategic direction and that the EMS requirements are incorporated into business processes.

Protecting the Environment

There are also proposed changes associated with the environmental policy requiring enhanced leadership commitment, including expanding the pollution prevention commitment to proactive initiatives to protect the environment from harm and degradation, consistent with the context of the organization. The revised text does not define ‘protect the environment’ but notes that it can include prevention of pollution, sustainable resource use, climate change mitigation and adaptation, protection of biodiversity and ecosystems, etc.

Performance

A heavier emphasis is placed on the determination of key performance indicators for all targets and objectives. The standard’s focus will shift from solely focusing on continuous improvement of the EMS to include continuous improvement of the EMS environmental performance indicators. The emphasis on understanding compliance status will shift the standard’s focus to outcomes rather than the current process orientation. Consequently, the system moves beyond a compliance focus to a performance based approach to environmental management and sustainability.

The 14001 standard has been written using the new high level structure which is uniform to all new management system standards, including the new Quality Management System Standard (ISO 9001) that is undergoing revision with final publication slated for end of 2015; and a new Health and Safety standards (ISO 45001) that is currently being drafted. The synergy created by strategically aligning key management systems will help organizations to capitalize on efficiencies, achieve performance improvements, and support sustainability and business objectives.

Those organizations that are currently certified to the ISO 14001:2004 standard are granted a three-year transition period after the final revision has been published to migrate their environmental management system to the new standard. During the three year transition period, organizations that opt for third party certification will seek certification under the 2015 standard while the 2004 certification will be rendered obsolete.

The Draft International Standard is available for purchase online.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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